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DIS Comments

 Contents                                                                                                                                    2010-01-03

Preface: Like this website the following deliberations and comments reflect the personal views and arguments of the author, not the view of any organization. It is emphasized that their intent is, as mentioned on this website’s homepage, to contribute as much to the success of this ISO project as possible.
In full respect of the sovereignty of ISO member bodies, it is in no way intended to influence their processes.

At a first glance these comments may be seen not so friendly but at a second glance they are more than constructive, to the best of ISO 26000 and its easy global use. The author apologizes for eventually causing other impressions.

Introduction
It is reminded that the ISO process has several stages. The voting on the preceding CD resulted in a vote that met the formal requirements of two thirds of the WG SR’s P-members voted in favor of promoting the document to the DIS stage; out of the  WG SR P-members having voting rights this had been 69 votes cast, 23 being against, 46 being in favor.

The main purpose of the CD vote, according to the ISO rules, is consulting the first time the ISO member bodies (not the WG SR members) and receiving the major concerns, if any, from the national committees, so that the draft standard can be amended/changed accordingly. This aims at getting these negative votes on the CD changed into positive votes on the DIS.

When reviewing the DIS document it is observed that several major concerns don’t seem to be sufficiently addressed.

1. Comments

The DIS stage, according to the ISO rules, is the appropriate stage to draw a line and see whether the draft will best meet its purpose, i.e. to globally promote a better social responsibility oriented behavior of organizations, regardless of their size, type and location, and whether the Design Specification in document N049 is met. Deliberations on valid options are a logical consequence.

Recognizing

  • the progress made since 2005
  • the project organization with its stakeholder approach as an ISO experiment in an area ISO may not be well prepared for, i.e. societal / “social engineering” standards
  • the complexity and incredibly broad nature of the subject of social responsibility
  • the cultural differences and characteristics of “societies” and “organizations”
  • the efforts made by all involved experts, observers and leadership, with particular appreciation of the IDTF’s work
  • the project costs so far exceeding some 72 million USD (51 at WG SR and 21 at national level),
     
  • Further recognizing that
  • success is the widest possible practical global use of ISO 26000
  • success is not the end of the project by reaching the final stage of publishing the ISO 26000 as an “International Standard”
  • the application of the DIS will cause problems for the vast majority of target users, which are SMOs.

The conclusion is that the DIS has not yet reached the quality that both an “ISO Standard” and the “area of social responsibility” deserve.

This is not at all criticizing WG SR experts or leadership who worked with utmost dedication,  emphasis and enthusiasm on the various drafts; it is rather questioning the suitability and preparedness of the ISO system to produce standards related to society.

In more detail the following comments address these items (see the downloadable “template”):

  • Characterization of “society”; missing an applicable definition
  • Need for a  multiple angle approach instead of an all-in-one approach
  • Practical guidance, Less SHOULDs, more HOWs; an 80 pages volume (without annexes) could only be justified if half of it offers practical guidance
  • Stakeholder selection; missing stakeholders that represent societies
  • Customer/user influence; missing user involvement, surveys and practical application tests
  • Volume of some 100 pages; self-containing document vs. referencing other sources; applicability for SMOs (small and medium organizations)
  • Complementarities to other “instruments and initiatives”; claimed but not demonstrated
  • Borderline between an ISO guidance standard and applicable law; not clear that in any case of doubt the national applicable law prevails
  • Relevance of all core subjects to every organization; inconsistency of statements
  • Limiting the scope of being applicable to all organizations; given examples of organizations for whom the ISO 26000 will not be applicable
  • Not meeting the NWIP requirements:
    -  being consistent with, and not in conflict with, existing documents, international treaties
       and conventions and existing ISO standards
    -  should be applicable by all types of organizations
    -  limiting proliferation of SR sector standards
    -  facilitate trade
    -  complement and avoid conflicts with other existing SR standards and requirements
    -  easy to understand
  • Applicability to governments; not clear that ISO 26000 would apply to governmentally owned or operated administrations and commercial organizations
  • Others can’t substitute governments’ role; missing guidance that governments need to fulfill minimum obligations including law enforcement mechanisms as a prerequisite for prospering societies
  • Problems with definitions:
    -  2.1.4 due diligence
    -  2.1.6 ethical behaviour
    -  2.1.10 international norms of behavior
    -  2.1.12  organization
    -  2.1.18 social responsibility
    -  2.1.20 stakeholder
  • The ISO system and its suitability for social and society related standards:
    -  national delegation principle; may not sufficiently include societal parties
    -  one-country-one-vote principle; may not adequately reflect the diverse sizes and
       kinds of societies
    -  handling of thousands of comments’; grouping tends to lose substance
    -  involvement of D-Liaison organizations in this project; when voting, their “voices”
       may not be adequately taken into account

Thus, the document N172 ISO/DIS 26000 would need further changes and improvements to met the expectations of users around the world. 

Can major changes to the document so late in the process be justified? Yes, they can, because the DIS phase formally, according to the ISO/IEC Directives, is the last phase where comments can be provided and major changes can be requested.

If proposed major changes are not made, the ISO 26000 may not become the success which the issue of social responsibility deserves. The next document edition would then rather get minor changes and would be launched for vote as FDIS (Final Draft International Standard), and in this “final” vote ISO member bodies can only vote YES or NO, without any opportunity to provide further comments.

2. Proposal

A. ISO’s unpreparedness for society related standardization

The ISO system of standardization is globally perceived and appreciated as a system for unification or harmonization of technical items. Its structures and procedures have evolved accordingly. There is a common global understanding that harmonization of technologies benefits mankind

Not so in society related areas. Societies want to maintain their identity and their differences to others. It would be a tremendous misconception to believe that there would be a “market demand” for any need for unification or harmonization of society related items. [It is reminded that COPOLCO, the ISO’s consumer policy committee originated the project idea in the days of scandals of unsocial behavior like the Enron and Worldcom examples, and that legislation has taken care of their non-repetition.]

There is not yet a common global perception as regards an ISO 26000 Guidance Standard. Since social and societal processes are evolutionary over longer periods of time, a successful project will need to approach social responsibility from multiple angles and be complementary to existing approaches and ongoing evolutions.

Such a project should
firstly identify globally shared objectives and
secondly emphasize a notion of accepted global diversity in following the guidance as best suited to existing geographical, cultural and legal environments. 

In this way, an international guidance document would rather be regarded by all legitimate institutions, including governments, as a desirable and diversified tool for realizing the shared objectives. Governments, in particular, would feel encouraged (not compelled) to provide the push for the guidance to be followed through commensurate legal and public policy changes at national, municipal, and local levels.

It would be counter-productive if such changes be seen as being imposed by outside forces, least of all by external profiteers from such changes, or from destruction of existing national or societal well-being and harmony.

With this in mind, the current DIS rather seems to follow Western culture and ways of thinking, and does not openly take into account Asian, Islamic or African cultures.

With this project experience of more than five years it is doubtful whether ISO, once founded for technical standardization, can be the right place for international standards on society related issues which normally, and should rightfully fall into the competence of national authorities and other national “social partners”.

B. Termination of the project with an ISO TR
The proposal is to save the current DIS as an ISO TR (“Technical Report”), even if it is not a “technical” document, and terminate the ISO 26000 project with this result.

The “Technical Report” thus can be regarded as a step in the search for an acceptable regime for Social Responsibility for a diversified world community of nations.

C. Consider the feasibility of the foundation of an international organization for society related benchmarks and standards, working title ‘SBS’

In view of the steadily increasing global population that will have to use only limited resources, the proposal is to consider the foundation of an international organization for society related benchmarks and standards, jointly founded by global organizations like the UN, ILO, ICC, IOE and WBCSD, and regional organizations like  ASEAN and APEC, so that all regions are adequately represented; ISO would take the role of a “special advisor”.

This organization SBS should be composed of members and personalities who can responsibly reflect the diverse societal needs and who are globally recognized for their personal competency.

The organization’s bylaws should be based on globally shared objectives for societal benchmarks and standards.

This organization should have its own working rules and directives that will differ significantly from the ISO/IEC Directives for technical work, particularly as regards

  • Members, “parties concerned” and stakeholders
  • Criteria for starting new work items
  • Direct participation of stakeholders, complementary to the ISO principle that “national delegations represent all parties concerned”
  • Processes and procedures including consensus mechanisms and voting rights, and
  • Duties and options for transposition and application of resulting societal standards into national portfolios.

The SBS organization could try a new project by re-writing the ISO/DIS 26000 towards a much shorter document that is based on globally shared objectives and

  • appropriately takes care of the world’s diversities of values, religions and cultures
  • recognizes the dynamics that push social responsibility at the national, municipal and local levels
  • is of an encouraging and motivating nature, not of a pedagogical style
  • is free of redundancies in itself
  • is free of overlaps with other international standards like the series ISO 14000, and
  • is free of overlaps with documents from other organizations.

 

3. Perpsectives

There are (at least) three routes worth mentioning.

Perspectives ABC

Perspectives ABC, slide2

These two slides are available for download in ppt format here.

4. Downloadable documents
The ISO/DIS 26000 is available for everyone on the ISO WG SR server under this link:
http://isotc.iso.org/livelink/livelink/fetch/2000/2122/830949/3934883/3935837/3974907/N172_ISO_DIS_26000__E_.pdf?nodeid=8385467&vernum=0

Further are the comments downloadable, in the form of the required “template”.

5.  Proposal for an “ISO 26000 compact”

Depending on the outcome of the 14 February 2010 DIS vote, there is an opportunity to maintain the current document as an “ISO Technical Report” and develop a condensed version that will find much broader market acceptance. Taking into account the experiences made with the ISO 26000 project, the development of an “ISO 26000 compact” would not take more than 2 months (net time) after having composed the drafting group appropriately.

An “ISO 26000 compact” should strive to achieve the following features:

  • Representation of societies: true representativeness of the multitude of globally existing societies by involving representatives of organizations including but not necessarily limited to religious, cultural, historical, medical groups (today’s WG SR “stakeholder” may cover at best, 50% of society)
     
  • Globally shared common values: work is based on an agreed set of globally shared common values on social responsibility (the DIS is more a collection of WG SR members’ wishes and wants rather than globally shared values);
     
  • Recognition of SR dynamics: an agreed  recognition of social responsibility as a dynamic process with an everyday-flexibility in regard to rapidly changing local demands;
     
  • Non-certification:
    Stating that the belief of having done everything possible by being certified ignores the SR spirit and dynamics and is counter-productive to the promotion of social responsibility;
    declaring certification against ISO 26000 is misuse and unsocial behavior; in addition,
    stating that “derivative-standardson social responsibility certification (which assert being “…in line with ISO 26000….” or similar) are unethical since the core standard ISO 26000 is intentionally not for certification;
     
  • An advance user survey: a professional user survey is performed before drafting text and its findings are taken into account when drafting;
     
  • Focused practical guidance: a document that is a true and focused guidance standard (the concept “less is more!” entirely applies);  a document that offers practical guidance on HOW to get the globally shared values supported (not a list of WHAT “should” statements, not a handbook with educational explanations);
     
  • Referencing other sources: a document that references other sources instead of again describing the issues (leads to a much shorter document);
     
  • Short and motivating: a motivating and convincing document that describes the benefits of acting in a socially responsible way, a document that everyone is eager to use; a document of 30 pages maximum that everyone is keen to study in its entirety , and is left with the desire to really do something towards better social behavior.

The proposal can be downloaded here, in Word format.

 

 

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